ML20236Y032
| ML20236Y032 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/08/1987 |
| From: | Terao D NRC OFFICE OF SPECIAL PROJECTS |
| To: | NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8712110043 | |
| Download: ML20236Y032 (10) | |
Text
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UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION 7,,.,
j WASHINGTON, D. C. 20555
\\...../
December 8, 1987 Docket Nos. 50-445 and 50-446 L
APPLICANT:
Texas Utilities Electric Company (TV Electric)
FACILITY:
Comanche Peak Steam Electric Station, Units 1 and 2
SUBJECT:
SUMMARY
OF AUDIT ON OCTOBER 5-9, 1987 - COMANCHE PEAK RESPONSE TEAM THIRD-PARTY REVIEW 0F TRAIN C CONDUIT LESS THAN AND EQUAL TO 2 INCHES AND SUPPORTS On October 5-9, 1987, the NRC staff and its consultants conducted an audit of the Comanche Peak Response Team (CPRT) third-party review of the Train C conduit (2 inches and under)* and support design validation at the Comanche Peak Steam Electric Station (CPSES).
The CPRT third-party review was performed by TENERA, L. P. (formerly known as TERA Corporation) as a part of Issue Specific Action Plan (ISAP) I.c.** under the charter of the CPRT Program Plan (Revision 4) dated June 18, 1987. A list of those persons involved with the audit is included in Enclosure 1.
The purpose of the audit was to assess the overall adequacy of the CPRT third-party (TENERA) activities associated with review of the CPSES Train C conduit design validation. The design validation of Train C conduit is being performed by Impell Corporation as a part of the TV Electric Corrective Action Program for design. The NRC staff audit included: (1)a review of the completeness of TENERA's activities and (2) a review of the CPRT Results Report ISAP I.c, " Train C Conduit and Supports," Revision 0 (hereafter referred to as the "Results Report").
Summary of Audit Team Review The Results Report has been reviewed by the TV Electric Senior Review Team (SRT). The SRT comments will be addressed by TENERA in Revision 1 to the Results Report. The Results Report addresses ISAP I.c and the Corrective Action Program for Train C conduit which Impell is currently implementing.
The TENERA review has focused on the criteria and methodology of the Impell seismic qualification program for Train C conduit. This included review of procedures, supporting documentation, and test programs. TENERA did not
- hereafter referred to as " Train C conduit"
- ISAP I.c " Train C Conduit and Supports" was formerly titled " Electrical Conduit Supports" 8712110043 B71208 ADOCK0500g5 PDR i
Summary of Audit 10/5-9/87 review Impell's. implementation of the Train C seismic qualification program.
'The implementation of the Train C seismic qualification program will be subject to audit by the TV Electric' QA Technical Audit Program.
As part of the NRC audit, the audit team reviewed the documents listed in.
The basis for documenting the third-party review is contained in CPRT Civil, Structural, Mechanical (CSM) Work Instruction CSM-5, Revision 0.
The memo method as described in CSM-5 was used to document the reviews in all but two cases. For two reviews, checklists were used. Therefore, the memoranda form the documented basis of the engineering evaluation performed by TENERA.
During the course of the third-party review, Discrepancy Issue Resolution Reports (DIR) and Requests for Information (RFI) were issued. TENERA has closed out-all DIRs and RFIs associated with Train C conduit.
The Results Report conclusion states, "The third party has concluded that Impell's Train C conduit / supports seismic qualification program is comprehensive and capable, if properly implemented, of meeting the FSAR and licensing commitments and resolving known technical issues." The basis for this conclusion is the memoranda issued in accordance with Procedure CSM-5. Most of the reviews were done in a qualitative manner and are documented in the memoranda.
The audit team noted that, in some cases, the last revision of a memorandum for a specific document had not closed out the review of the document since either an RFI or a DIR had been issued.. TENERA has not formally closed out these memoranda.
Page 12 of the Results Report stated that " Project Personnel were qualified to applicable Project Procedures." TENERA informed the audit team that this was a statement of fact as given in the ISAP and TENERA did not audit the qualifications of personnel.
TENERA will clarify this.
CONCLUSIONS Overall, the audit team found that the third-party review was accomplished in a thorough manner by well-qualified personnel.
The third-party review of the seismic qualification program for Train C conduit included reviews of walkdown and seismic qualification procedures, special studies, tests i
and overall program methodology.
The staff found that there was adequate depth and breadth to the third-party review of these activities.
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Summary of Audit 10/5-9/87 1 However, the audit team found that the Results Report, as currently written, does not accurately describe the method of approach used by TENERA in its
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third-party review of the Train C conduit seismic qualification program.
The audit team recommended that the Results Report be revised to more accurately l
describe the review TENERA actually performed as documented in the memoranda discussed above.
I I
l The audit team identified the following items which TENERA should identify and transfer to the TU Electric Technical Audit Program (TAP) for continuity of review:
i qualifications of project personnel (Impell) especially for Screen Level 6; review of Screen Levels 1 and 7 (if used by Impell);
areas of implementation audited by TENERA (supply May 1987 TENERA Implementation Audit to the TAP).
The audit team identified the following open item and will follow up its resolution in a future audit:
TENERA must assure that all memoranda are adequately closed out in order to ensure that a closed, auditable trail exists.
In the exit meeting TENERA stated that they have put in place a program to review and resolve all memoranda which were not formally closed out.
The audit team will conduct a followup audit to ensure proper close-out of the memoranda.
David Terao, Mechancial Engineer Comanche Peak Project Division Office of Specici Projects
Enclosures:
- 1. List of Persons Involved with Train C Audit
- 2. List of Docunents Reviewed cc: See next page s
9 t
W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Electric Company Units 1 and 2 cc:
Thomas G. Dignan, Jr.
Asst. Director for Inspec. Programs Ropes & Gray Comanche Peak Project Division l
225 Franklin Street U.S. Nuclear Regulatory Commission Boston, Massachusetts 02110 P. O. Box 1029 Granbury, Texas 76048 Robert A. Wooldridge, Esq.
Regional Administrator, Region IV Worsham, Forsythe, Sampels &
U.S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin 1
Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street i'
Texas Utilities Electric Company Washington, D.C.
20002 Skyway Tower 400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde, Esq.
Dallas, Texas 75201 Government Accountability Project Midwest Office Mr. Robert E. Ballard, Jr.
104 East Wisconsin Avenue Director of Projects Appleton, Wisconsin 54911 i
Gibbs and Hill, Inc.
11 Penn Plaza New York, New York 10001 David R. Pigott, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. R. S. Howard San Francisco, California 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.
Pittsburgh', Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Renea Hicks, Esq.
Washington, D.C. 20005 Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12548, Capitol Station Bonnie S. Blair Austin, Texas 78711 Spiegel & McDiarmid 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy 1426 South Polk George A. Parker, Chairman Dallas, Texas 75224 Public Utility Committee Senior Citizens Alliance Of Ms. Nancy H. Williams Tarrant County, Inc.
CYGNA Energy Services 6048 Wonder Drive l
2121 N. California. Blvd., Suite 390 Fort Worth, Texas 76133
(
Walnut Creek, CA 94596 4
l 3 W. G. Counsil Comanche Peak Electric Station Texas Utilities Electric Company Units I and 2 cc:
Joseph F. Fulbright Jack R. Newman, Esq.
Fulbright & Jaworski Newman & Holtzinger, P.C.
1301 McKinney Street Suite 1000 Houston, Texas 77010 1615 L Street, N.W.
Washington, D.C. 20036 Roger D. Walker Manager, Nuclear Licensing Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette, Esq.
Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C.
20007 James P. McGaughy, Jr.
GDS Associates, Inc.
Suite 720 1850 Parkway Place Marietta, Georgia 30CJ7 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington 0.C.
20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Administrative Judge 881 West Outer Drive Oak Ridge, Tennessee 37830
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List of Persons. Involved With Audit of Train C Conduit Less Than and Equal to 2 Inches and Supports On October 5-9, 1987 TV Electric J. Finneran S. Hanson R. Lynn Natzic TENERA T. Snyder C. Mortgat D. Nyman NRC Staff and Consultants J. Lyons*
D. Terao*
J..Flaherty (Teledyne Engineering Services)
E. Solla (Teledyne Engineering Services)
- Part-time 1
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LIST OF DOCUMENTS REVIEWED DURING AUDIT OF CPRT THIRD-PARTY REVIEW 0F TRAIN CONDUIT LESS THAN AND EQUAL TO 2 INCHES AND SUPPORTS OCTOBER 5-9, 1987 CPRT Work Instruction CSM-2', " Preparation and Control of Engineering Evaluations,"
Rev. O.
CPRT Work Instruction.CSM-3, " Preparation and Control'of Calculations," Rev. O.
CPRT Work Instruction CSM-5, " Documenting Third-Party Reviews," Rev. O.
TERA Memorandum, J. Groncki to C. Mortgat, Review of Impell Report #01, 0210-1479, Rev. 1, " Criteria Document" (Evaluation 33101-02), March 24, 1987.
TERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell. Project Instruction 0210-052-003, " Seismic ~ Evaluation of Train C Conduit Supports," Revision 3 (Evaluation 33103-02), September 14, 1987.
TENERA Memorandum, J. Groncki to C. Mortgat, Completien of Review of Impell Report #01-0210-1483, Rev. O, February 1986.
Portion of Action Plan I.c, Task 4.2.3 (Evaluation 33105-02),' June 23, 1986.
TERA Memorandum, J. Groncki to C. Mortgat, Review of Impell Report, "Justifi-cation of Factor of Safety," Report 01-0210-1483, Rev. 2, December 1986 (Draft for Comment), (Evaluation 33105-02), March 4, 1987.
TERA hemorandum, J. Groncki to C. Mortgat, Review of Impe11 Report, "Justifi-cation of Factor of Safety," Report 01-0210-1483, Rev. 2 (Evaluation 33105-03),
September 18, 1987.
TERA Memorandum, S. L Shein to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Instruction PI-0210-052-006, Rev. 1, " Rigorous Analysis of Train C Electrical Conduit," (Evaln tion 33108-02), July 20, 1987.
TERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impe11 Instruction PI-0210-052-006, Rev. 1, " Rigorous Analysis of Train C Electrical Coaduit" (Evaluation 33108-02), July 20, 1987.
TERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impe11 Project Instruction 0210-052-011, " Procedures for Utilizing. Test Data on Train C Conduit Support Components," Rev. 0 Evaluation 33112-01), August 28, 1987.
TENERA Memorandum, J. Groncki to C. Mortgat, Review of PI-0210-053-001, Rev. 3, Part I, Portion of Action Plan I.c, Task 4.2.3 (Evaluation 222301-01),
August 11, 1986.
TENERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Completion of the Review of Impell Report PI-0210-053-001, Rev. 5, Part I (Evaluation 333401-03), September 15, 1986.
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' i TERA Memorandum, R. Brown to " Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Instruction PI-0210-053-001, Rev. 6, Part I, " Multi-Level Screening Criteria for Train C Conduit" (Evaluation 333401-04), December 30, 1985.
TERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Project Instruction 0210-053-001, Rev. 7, " Multi-Level Screening Criteria for Train C Conduit" (Evaluation 333401-05) September 18, 1987.
TENERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Instruction PI-0210-052-01, Rev. 2, " Procedures for Implementation of Screen Level 6" (Evaluation 33409-01), December 5, 1986.
TENERA Memorandum, J. F. Giova to C. Mortgat, Review of CCL Report No. A-711-86,
" Static Testing of Train C Conduit Support Components 4/4/86" (Evaluation 33501-01)
June 26, 1986.
TENERA Memorandum, J. Groncki to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of CCL Test Procedure #1903.23-01, (Evaluation 33503-01), June 30, 1986.
TENERA Memorandum, C. Savant to C. Mortgat, Completion of Review of Impell Calculation ROTC-02, " Procedures to Calculate Anchor Bolt Loads TUGC0 Train C Conduit 2" 0" (Evaluation 33611-01), June 25, 1986.
TERA Memorandum, R. Brown tn C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-02, " Procedure to Calculate Anchor Bolt Loads,"
Rev. 2, (Evaluation 33611-02), May 29, 1987.
TERA Memorandum, J. Groncki to C. Mortgat, Review of Impell Report, " Relevance of Anchor Bolt Installation Torque Verification," Report No. 01-0210-1583, Rev. A (Draft for Comment), (Evaluation 33609-01), March 3, 1987.
TERA Memorandum, J. Groncki to C. Mortgat, Review of Impell Report #01-0210-1583, Rev. O, " Anchor Bolt Installation Torque Issue" (Evaluation 33609-02), April 3, 1987.
TERA Memorandum, R. Brown to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-08, Rev. O, " Junction Box Stiffness" (Evaluation 33618-01), March 10, 1987.
TENERA Memorandum, C. Savant to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-32, Pev. 1, " Stiffness Calculation for Train C Supports" (Evaluation 33620-01), October 17, 1986.
TENERA Memorandum, R. Brown to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-25, Rev. 1, " Allowable Conduit Span Lengths Adjacent to CI Boxes" (Evaluation 33621-01), December 11, 1986.
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' TENERA Memorandum, R. Brown to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-25, Rev. 2, " Allowable Conduit Span Lengths Adjacent to CI Boxes: (Evaluation 33621-02), January 21, 1987.
TENERA Memorandum, D. J. Nyman to C. Mortgat, "CPSES Train C Conduit, Justi-fication of Damping Value," Impell Report No. 01-0210-1527 (Evaluation 33622-01),
October 21, 1986.
TENERA Memorandum, D. J. Nyman to C. Mortgat, "CPSES Train C Conduit, Justi-fication of Damping Value," Impell Report No. 01-0210-1527, Rev. 1, (Preliminary),(Evaluation 33622-02), November 25, 1986.
TERA Memorar.dum, J. Groncki to C. Mortgat, "CPSES Train C Conduit, Justi-fication of Damping Value," Impell Report No. 01-0210-1527, Rev. 1, (Evaluation 33622-03), September 14, 1987.
TERA Memorandum,-R. Brown to C. Mortgat, Action Plan I.c, Task 4.2.3, Review of Impell Calculation ROTC-43, Rev. O, " Minimum Edge Requirements for Bolts Near a Concrete Chamfer Edge" (Evaluation 33624-01), January 13, 1987.
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December 8, 1987 Sunmary of Audit 10/5-9/87 DISTRIBUTION:
. Docket:F11e.(50-445/446)m NRC "PDR '
Local PDR OSP Reading CPPD Reading SEbneter/JAxelrad CIGrimes PFMcKee JElyons RFWarnick MMalloy Avietti-Cook DTerao CPPD-LA OGC-Bethesaa FMiraglia EJordan JPartlow ACRS (10)
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- tietti-Co k :JElyo s DATE
- 12/i /87
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- 12/,1/87
- 12/4 /87
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